Remember to review, certify, and post your OSHA 300A starting February 1 to April 30. For more info on Recordkeeping
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HIOSH Injury and Illness Recordkeeping and Reporting Requirements

Disclaimer

HIOSH makes every effort to ensure that this webpage is accurate and up-to-date; however, for the latest information please contact our office.

Overview

Currently, HIOSH §12-52.1-2, HAR incorporates the federal standard, 29 Code of Federal Regulations Part 1904, specifically the 2017 Edition published as of July 1, 2017. Therefore information on this webpage pertains to those under HIOSH jurisdiction.

Recordkeeping Requirements

Employers with more than 10 employees are required to keep OSHA Injury and Illness record(s) (i.e., OSHA 300, 300A, and 301 forms) of serious work-related injuries and illnesses (certain low-risk industries are partially exempted see §12-52.1-2, HAR Appendix A to Subpart B). Minor injuries requiring first aid only do not need to be recorded.

This information helps employers, workers and HIOSH evaluate the safety of a workplace, understand industry hazards, and implement worker protections to reduce and eliminate hazards -preventing future workplace injuries and illnesses.

Maintaining and Posting Records

The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary (i.e., OSHA 300A) of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to employees, or their representatives.

Reporting Requirements

Report to HIOSH office via telephone (808) 586-9102 or in person at the HIOSH office (830 Punchbowl St #425., Honolulu, HI 96813) of the following (§12-52.1, HAR):

  • within 8 hours after the death of an employee from work-related incident; and
  • within 24 hours of:
    • inpatient hospitalization of an employee
    • employee’s amputation
    • employee’s loss of an eye as a result of a work-related incident
    • property damage in excess of $25,000 as a result of work-related incident.

When the HIOSH office is closed, the (808) 586-9102 telephone number will allow you to leave a phone message. In order for the message to be considered officially reported, all of the information in 29 C.F.R. §1904.39(b)(2) must be provided on the answering machine message (see FAQs What Information do I need to give to HIOSH when reporting?).

Electronic Submission of OSHA Injury and Illness Forms

Covered establishments must electronically submit to the Injury Tracking Application (ITA) their OSHA injury and illness data by March 2 of the year following the covered year of the data. For example, for submission of calendar year 2024 data, that date is March 2, 2025. Submission window to submit is between January 2nd to March 2nd annually.

Private Sector Employers

Establishments with 250 or more employees. If your establishment had 250 or more employees at any time during the previous calendar year and this part requires your establishment to keep records, then you must electronically submit information from OSHA 300A Summary of Work-Related Injuries and Illnesses to OSHA or its designee (e.g., Injury Tracking Application).

Certain Establishments with 20-249 employees. If your establishment had 20 or more employees but fewer than 250 employees at any time during the previous calendar year, and your establishment is classified in an industry listed in Appendix A to Subpart E of this part, then you must electronically submit information from OSHA 300A Summary of Work-Related Injuries and Illnesses to OSHA or its designee (e.g., Injury Tracking Application).

Upon notification: You must electronically submit the requested information from your OSHA injury and illness records to OSHA or OSHA’s designee (e.g., Injury Tracking Application).

Public Sector Employers

State and City & County Government Agencies (only): Upon notification from HIOSH office, submit the requested OSHA Injury & Illness Record(s) to dlir.hiosh.records@hawaii.gov specified in the notification. Do not submit any information to Injury Tracking Application.

Frequently Asked Questions (FAQs)

Recording

All employers covered by the Hawaii Occupational Safety and Health Law (HIOSH Law) are subject to the recordkeeping requirements unless specifically exempted.

Two partial exemptions are provided from recordkeeping requirements:

  • small employer exemption – 10 or fewer employees at all times during the year
    • unless informed by government to keep records under 29 CFR §1904.37, §1904.41, or §1904.42.
  • low-hazard industry exemption – listed under §12-52.1, HAR
    • unless informed by government to keep records under 29 CFR §1904.37, §1904.41, or §1904.42

#partial-exempts

Per §12-52.1, HAR, an amputation is the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, which has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; and amputations of body parts that have since been reattached.

#amputation

HIOSH/OSHA defines in-patient hospitalization as a formal admission to the in-patient service of a hospital or clinic for care or treatment. Treatment in an Emergency Room only is not reportable.

#in-patient-hospitalization

  • Any work-related fatality.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
  • There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

#recordable-cases

The following is a complete list:

  • Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
  • Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin
  • Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
  • Using hot or cold therapy;
  • Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
  • Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
  • Using eye patches;
  • Removing foreign bodies from the eye using only irrigation or a cotton swab;
  • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
  • Using finger guards;
  • Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
  • Drinking fluids for relief of heat stress.

Any treatment not included in this list is not considered first aid for recordkeeping purposes.

#first-aid

OSHA 300, 300A, 301 and Instructions (PDF)(Excel)

If your business changes ownership, then you are responsible for recording and reporting work-related injuries and illnesses only for that period of the year during which you owned the establishment.

You must transfer the part 1904 records to the new owner. The new owner must save all records of the establishment kept by the prior owner, as required by §1904.3, but need not update or correct the records of the prior owner.

#forms-ownership

The employer must establish and inform employees a reporting work-related injuries and illnesses. The Recordkeeping rule allows flexibility in creating reporting systems.

Effective reporting systems depend on workforce size, employee’s language proficiency and literacy levels, the workplace culture, and other factors will determine what will be effective for any particular workplace.

#employer-reporting-system

Reporting

All employers under HIOSH jurisdiction must report these incidents to HIOSH, regardless of whether they are exempt from the maintaining OSHA 300 and related forms due to their partial exemption status (either due to small employer or low-hazard industry). 

§12-52.1, HAR requires you to report either in-person at the HIOSH office or call (808) 586-9102 and/or leave a voicemail with the following required information:

  1. The establishment name;
  2. The location of the work-related incident;
  3. The time of the work-related incident;
  4. The type of reportable event (i.e., fatality, in-patient hospitalization, amputation, or loss of an eye, property damage greater than $25,000);
  5. The number of employees who suffered a fatality, in-patient hospitalization, amputation, or loss of an eye;
  6. The names of the employees who suffered a fatality, in-patient hospitalization, amputation, or loss of an eye;
  7. Your contact person and his or her phone number; and
  8. A brief description of the work-related incident.

#reporting-info

Similar to the requirements in section 29 CFR 1904.31 for recording injuries and illnesses, the employer that provides the day-to-day supervision of the worker must report to HIOSH any work-related incident resulting in a fatality, in-patient hospitalization, amputation, loss of an eye.

Electronic Submission of OSHA Injury and Illness Forms

FAQs for the OSHA-managed ITA is found at https://www.osha.gov/injuryreporting/faqs

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